BOSTON — Nursing home operators must do better to prepare for annual surveys — despite many facilities sometimes being subjected to years-long backlogs in some jurisdictions — experts said.
Often, it may simply mean remembering, and then using, tools that are available and conducting a rigid “maintenance” schedule. All activity must be driven by steady preparation protocols, according to session speakers at the LeadingAge Annual Meeting here.
“Do your mock surveys, QAPI your findings, audit your findings, and coach and lead your teams from the improvement aspect,” advised Peggy Connorton, associate vice president of Healthcare Regulation, Compliance and Quality with Skokie, IL-based Covenant Living Communities and Services. “And look at this as an opportunity for improvement, not something to fear.”
“Turning Survey Prep Into Confidence, Not Chaos” was the tagline of an educational session led by Connorton and Wendy Strain, director of consulting for Polaris Group on Monday. Staying ahead of the eventuality of a grueling survey is a must, Connorton emphasized.
“Being prepared, having your state survey notebooks ready, having all your entrance conference information ready before the surveyors come. You can set up a cadence of getting that information on a weekly basis, even if you’re not in the survey window,” she told McKnight’s Long-Term Care News in a follow-up interview Tuesday.
While that may sound basic, she added that the biggest challenge for many providers is “having the time to do it — you have to put it into your daily practice.”
Handy tips
“Build a culture of readiness,” Connorton and Strain advised. Daily preparation and routines are a cornerstone of this thinking.
Start the day with a 10-15 minute “safety huddle,” they advise. This would include the building administrator, director of nursing, charge RN, and dietary, housekeeping, activities and social services reps. Any “misses” from the day before and/or complaints should be discussed, and an “owner” of the resolution to each problem should be determined.
Also discussed should be a “Top-5 risk dashboard” for the day. Conclude with a few lines about staffing assignments and any high-risk residents for the shift. Depart having three “focus items for the day,” again assign an “owner” for each of them, and post it all on a visible board.
Leaders should also make daily “visibility rounds,” partly to check on procedures but perhaps just as much to show accessibility and support for staff. And do them even on busy or “bad” days.
Micro audits should last no more than 10 minutes each in the following areas: spot medication and treatment administration records checks on two residents; quick checks on a handful of dietary/kitchen items; important checks of egress, door alarm operability, crash carts and similar; pulling two recent MDS records to confirm diagnosis support and Section GG coding accuracy; and finally a weekly check of high-risk meds and. med storage security.
They also recommended three resident of family mini interviews, asking: “Do staff respond quickly?”, “Are you treated with kindness?” and “Any pain today?”
“Close loops the same day, and fix or elevate to the appropriate department,” Strain said.
Connorton said a big part of that at Covenant Living involves having nurse leaders prepare pocket guides about each patient for their respective nurse aides. The guides consist of a physical page of vital patient care information about each patient.
“It has the important things to remember, like their transfer status, ADLs, and they just update that where the CNAs can carry that in a pocket,” Connorton explained. “I’m sure some others do it like that [as well] but we picked it up as a best practice for our communities to do. The CNAs like it because then they don’t have to remember everything or have everything in the EMR. They have everything and can look for it.”
Covenant Living is one of the largest US not-for-profit continuing care retirement community organizations in the US, with 20 campuses in 11 states.
“If you’re hesitant,” Connorton said, “preparedness gets you through the survey. Quality leads to good outcomes.”
A big part of being prepared involves pre-testing via mock surveys, said Strain, who called them “the great game-changer.”
She emphasized that any kind of mock survey can be helpful, but when performed by individuals outside of the organization in focus, the results can be more helpful.
“Objectivity turns mock surveys from internal review into learning opportunities,” she said.
Need for caution
But even then, when dealing with known colleagues or outside groups as third-party reviewers, independence is a key, Connorton said.
“Sometimes when you have someone you know, you have that familiarity with each other and you can have conversations, or you may not want to cite their area, or be negative about their community,” she observed. “So you must be making sure if you do have people who are familiar with each other, have that line in the sand and emphasize that this [exercise and any criticism] is to make us better as a community.”
Borrowing from the “ignorance is not bliss” line of thinking, she added that it’s better for a provider to take any lumps and risk getting a bruised ego up front under mock survey conditions than suffering worse consequences later at the hands of actual investigators.
“It’s hard to hear criticism, but the surveyors are going to give you criticism,” she said. “And sometimes it’s better to hear it from a friendly face [first] than a surveyor. It’s hard if you hear it from a friend or a colleague, but it makes you better as a community.”
Similarly, Strain told providers to embrace hearing about complaints from residents and family members.
“I like grievances,” she said. “If I know about it, I can fix it … if I know about it.”
The presenters cautioned that a facility’s kitchen is virtually always “one of the first things” surveyors will enter when they visit on an official visit.
Correspondingly, food prep and other kitchen situations have been the second-most cited in recent years, according to government statistics. As a result, they are considered a point of emphasis moving forward.